Epr registration for waste oil
Extended Producer Responsibility (EPR)
Empower your business to achieve seamless EPR compliance and contribute to a sustainable future with NETZERO India’s expert guidance.
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The Ministry of Environment, Forest, and Climate Change (MoEFCC) of India has recently announced an amendment to the Hazardous Waste Management Rules, introducing new provisions for Extended Producer Responsibility (EPR) specifically for Used Oil. This amendment, effective from April 1, 2024, aims to regulate the management of waste oil produced by manufacturers, importers, and recyclers. This move follows the previous introduction of EPR for Tyre Waste in 2022, emphasizing the Indian government’s commitment to environmental protection through efficient waste management.
EPR Mandate
Producers, Importers, and Brand Owners (PIBOs) must take full responsibility for managing plastic waste generated from their products.
Sustainable Practices
Includes recycling, reuse, waste-to-energy conversion, plastic-to-oil technologies, and safe disposal methods.
Circular Economy
Reduces environmental impacts and promotes a circular economy approach to plastic waste management.
Understanding Extended Producer Responsibility (EPR)
Under the PWM Rules, 2016, EPR is a legal obligation for all PIBOs operating in India. Regardless of scale or turnover, if your business involves plastic packaging, you are required to manage the lifecycle of plastic waste generated from your operations.
Co-processing in cement kilns
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Plastic-to-oil conversion
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Reprocessing and recycling
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Waste-to-energy solutions
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Understanding Used Oil
Used oil, as defined under Rule 3 of the Hazardous Waste Management Rules of 2016, includes any oil derived from crude oil or synthetic mixtures that are suitable for reprocessing. This encompasses spent engine oil, gear oil, hydraulic oil, and others, provided they meet specific criteria outlined in Part A of Schedule V of the rules. Used oil does not include waste oil, which has different disposal requirements.
Role of EPR Compliance for Used Oil
India’s fifth EPR policy, for Used Oil, aims to manage it sustainably, promoting a circular economy and ensuring all stakeholders—producers, recyclers, collection agents, and importers—follow strict disposal and recycling guidelines. This framework reduces environmental risks like contamination and greenhouse gas emissions by encouraging re-refined oil use, ultimately conserving natural resources and decreasing crude oil dependency, thus safeguarding environmental health and fostering sustainable industrial practices.
Entities Required for EPR Registration for Waste Oil
Producers: selling base or lubrication oil within India.
Recyclers: engaged in the recycling of used oil.
Collection Agents: collecting waste oil and supplying it to registered recyclers.
Used Oil Importers: importing used oil for re-refining purposes.
Responsibilities Under EPR for Waste Oil
Stakeholders must fulfill specific responsibilities to comply with EPR regulations:
Producers must register for EPR through the CPCB portal, set up collection systems, and file regular returns.
Collection Agents must gather used oil from generators and supply it to recyclers or producers.
Recyclers must follow CPCB guidelines for recycling processes.
Importers must ensure that imported used oil is only used for re-refining and comply with all regulatory requirements.
The new amendment to the Hazardous Waste Management Rules mandates several responsibilities for various stakeholders involved in the production, collection, recycling, and import of used oil. Here are the key responsibilities for each group:
EPR Registration: must obtain EPR registration for used oil through the CPCB (Central Pollution Control Board) portal.
EPR Targets: They are responsible for meeting their EPR targets, which are set based on the amount of lubrication or base oil sold.
Collection and Storage: Producers must arrange for the collection, transportation, and storage of used oil.
Contact Information: They need to provide contact details via their website or other means to facilitate the collection process.
Awareness Programs: Producers are required to spread awareness about used oil collection and recycling through various communication channels.
Record Keeping and Reporting: They must file annual and quarterly returns online, providing detailed reports on used oil generation and recycling.
Registration: agents need to register on the CPCB portal.
Collection and Supply: are responsible for collecting used oil from generators and supplying it to registered recyclers or producers.
Collection and Storage: Producers must arrange for the collection, transportation, and storage of used oil.
Compliance: that they comply with all regulatory requirements and report their activities accurately.
Record Keeping and Reporting: They must file annual and quarterly returns online, providing detailed reports on used oil generation and recycling.
Registration: must register on the CPCB portal and cannot engage with non-registered entities.
Recycling Processes: should adhere to the CPCB guidelines for recycling used oil.
Certification: issue EPR certificates to producers upon recycling used oil, detailing the quantity and compliance.
Reporting: must submit annual and quarterly reports on the recycling process to the CPCB.
Record Keeping and Reporting: They must file annual and quarterly returns online, providing detailed reports on used oil generation and recycling.
- EPR Registration: Importers of used oil must register on the CPCB portal.
- EPR Targets: Obligated to recycle 100% of the previous year’s imported used oil.
- Usage Restriction: Used oil is restricted to re-refining only; non-compliance risks registration cancellation and legal action.
Documents Required for Used Oil EPR Compliance
Registration Documents:
- ID and Address Proof of Authorized Persons: ID and address proof of individuals responsible for compliance.
- Business Registration Documents: Certificate of Incorporation (CIN), Memorandum of Association (MOA), Partnership Deed, MSME registration, etc.
- PAN and GST Details: Permanent Account Number (PAN) and Goods and Services Tax (GST) registration details of the business.
- Import Export Code (IEC): for importers of used oil.
Operational Documents:
- Details of Manufacturing: about the manufacturing process, including machinery used and the production capacity.
- EPR Plan: comprehensive plan detailing how the business intends to meet its EPR targets for used oil.
- Annual Returns: of annual returns filed previously, indicating the quantity of used oil generated and managed.
- Data on Used Oil Generation: data on the generation of used oil, including quantities and sources
Compliance Documents:
- EPR Registration Certificate: of EPR registration issued by the Central Pollution Control Board (CPCB).
- Collection and Transportation Records: showing the arrangements made for the collection, transport, and storage of used oil.
- Recycling Agreements: or contracts with registered recyclers indicating the supply of used oil for recycling.
- EPR Certificates: issued by recyclers confirming the quantity of used oil recycled.
Reporting and Audit Documents:
- Annual and Quarterly Reports: reports submitted online to the CPCB, detailing used oil management activities.
- Environmental Audit Reports: from environmental audits conducted by the CPCB or authorized third parties verifying compliance with EPR obligations.
Additional Documents:
- Awareness Campaign Records: of awareness programs conducted to inform stakeholders about used oil collection and recycling.
- Contact Information: details provided through the business’s website or other communication mediums to facilitate the collection process.
- Environmental Compensation Records: applicable, records of environmental compensation paid for non-compliance with EPR obligations.
Maintain the Documents
- By maintaining these documents, businesses ensure that they meet all regulatory requirements for EPR compliance, facilitating a smooth and efficient process for managing used oil. This documentation not only helps in regulatory adherence but also supports the overarching goal of environmental sustainability and resource efficiency.
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Frequently Asked Questions
Those manufacturing or importing base/lubrication oils under their brand
Spent engine, gear, hydraulic, turbine, compressor, transformer oils, or tank
Producers, importers, collection agents, and recyclers of used oil
Oils such as white oil, process oils used in manufacturing processes, as well as lubricants such as greases, etc., which do not lead to generation of any residual used oil, may not have EPR obligation. However, the concerned Producers have to get registered on EPR Portal.
Yes, the Producer of oil exempted from Used Oil EPR Target, still need to register on the Used oil portal and submit the details to verify their claim. Further upon evaluation, CPCB may exempt the EPR targets provided that the declared oil does not contribute to the generation of used oil.
Producers: Start at 5–10% (2024–26), increase annually to 50% by 2030–31 Used oil importers: Must recycle 100% each year.
Through EPR certificates issued by recyclers using:
By purchasing the required certificates annually via CPCB’s portal
All entities must register, pay fees, maintain records, and file quarterly/annual returns (due by June 30 each year)
The units which are established after 1st April, 2024, the extended producer responsibility obligation will start after two years from the end of the financial year in which the unit was established.
Bulk generator is any entity like automobile industry or railways or defence establishments or a transport company or industrial units or power transmission company or hotels or restaurants and other such entity which is generating more than 100 metric tonnes of used oil per annum.
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